PRIVACY POLICY

Last Updated: September 1, 2016

We, New Three Inc., a.k.a. New Three University (“NTU”), want you to enjoy and benefit from our websites and online services secure in the knowledge that we have implemented fair information practices designed to protect your privacy. NTU owns and operates several public-facing websites, including newthreeuniversity.com, as well as makes the same or similar content available to mobile users, including via apps available to users of Android, iPhone, iPad or any other mobile device, (collectively the "Sites")

Our privacy policy (the “Privacy Policy”) is applicable to the Sites and describes the kinds of information we may gather during your visit to the Sites and otherwise, how we use your information, when we might disclose your personally identifiable information, and how you can manage your information.

This Privacy Policy does not apply to websites maintained by other companies or organizations to which we may link or who may link to us. We are not responsible for the actions and policies of third-party websites.

By visiting our Sites, you are accepting the practices described in our privacy policy, including our use of cookies and similar online tools. If you do not agree to the terms of this Privacy Policy, please do not use the Sites. We reserve the right to modify or amend the terms of our Privacy Policy from time to time without notice. Your continued use of our Sites following the posting of changes to these terms will mean you accept those changes. If we intend to apply the modifications or amendments to this Privacy Policy retroactively or to personally identifiable information already in our possession, we will provide you with notice of the modifications or amendments and seek your consent for such use.

What Information Is Collected?

How Do the Sites Use Cookies and Other Tracking Technologies?

How Do We Use Your Information?

Who Can See Your Information?

What Are Your Choices?

Governing Law & Notice to Non-U.S. Users

Other Important Information

Questions About this Policy; Access to Your Information

What Information Is Collected?

We collect two basic types of information from you in conjunction with your use of the Sites: non-personally identifiable information and personally identifiable information. Non-personally identifiable information does not individually identify you, but it may include tracking and usage information about your general location, demographics, use of the Sites and the Internet. Personally identifiable information is any information that can individually identify you and includes, your name, address, phone number, and email address, or non-personally identifiable information that has been linked to such personally identifiable information.

Personally Identifiable Information

As a general matter, you can browse the Sites without submitting your personally identifiable information to us. However, there are a number of circumstances in which you may supply us with your personally identifiable information, including when you subscribe to our publications, newsletters, and other content; set up an account/profile; place an order; register for an event; register for services; register for a Site or any part thereof; complete a survey or participate in market research; enter a contest; upload content; send us an email; or when you seek employment at NTU. Additionally, you may be provided, or required to choose, a password and/or User ID, and you may provide a credit, debit, or charge card number, or other payment information, as well as your name, telephone number(s), email and/or street address, and other personally identifiable information. Other information such as your age, gender, an avatar, and the number for your mobile or other device may also be requested. In addition, you may be asked to send us similar information via messaging (e.g., email, SMS, MMS, or other technologies).

Non-Personally Identifiable Information

When you interact with the Sites, we may collect certain information that does not identify you individually (“non-personally identifiable information” or “non-PII”), such as demographic data, information about your computer, mobile device, or other device that you use to access the Sites, including IP address, general location information, unique device identifiers, browser type, browser language, and other transactional information. We may also collect information about your use of the Sites, including your search terms and search results, and additional “traffic data” such as time of access, date of access, software crash reports, session identification number, access times, and referring website addresses. Our servers or hosting company may automatically keep an activity log of your use of our Sites. In addition to non-identifiable individual information, we may collect aggregate data regarding the use of the Sites.

Collection of Personally Identifiable Information from or Through Social Media Sites

In addition, when you interact with any NTU property page or account on a social media platform, such as Facebook, Twitter, Tumblr, Instagram, Google+, or LinkedIn, we may collect the personally identifiable information that you make available to us on that page or account including your social media account ID. However, we will comply with the privacy policies of the corresponding social media platform and we will only collect and store such personally identifiable information that we are permitted to collect by those social media platforms. If you choose to link or log in to your NTU account with or through a social networking service, NTU and that service may share certain information about you and your activities. With your consent, we also may share information about your activities, including what you view on the Sites, with that social network’s users.

User Generated Content and Public Activities

We offer you opportunities to engage in public activities on the Sites. Public activities are any actions you take on the Sites that are designed to be visible to other users, including comments, recommendations, reviews, ratings, or any other items that you submit. Any information you disclose in your public activities, along with your screen name or ID, or any image or photo, becomes public and may be used by NTU for online and offline promotional or commercial uses in any and all media. If you choose to engage in public activities, you should be aware that any personal information you submit can be read, collected and used by other users of these areas. We are not responsible for the personal information you choose to submit in the course of your public activities and we have no responsibility to publish, take down, remove or edit any of your public activities or submissions.

Public activities may be included in our RSS feeds, APIs and other distribution formats. As a result, your public activities may appear on other websites, blogs, or feeds. Keep in mind that we are not responsible for any personal information you choose to make public via your public activities, and you agree that such sharing will be deemed to have been done by you, not NTU.

Collection of Your Source IP Address/Location Information

We collect and store your device’s source Internet Protocol (“IP”) address which may disclose the general location of your device at the time you access the Sites, your company or your university or your Internet Service Provider. Advertisements and certain content may be directed to you as a result of this data. We may use your IP address to help diagnose problems with our servers, gather broad demographic information, and administer the Sites.

Collection of Personally Identifiable Information from Events

We receive personally identifiable information about attendees to our events, conferences and workshops from sign-in and registration lists. We may use this information ourselves and share it with event or promotion sponsors.

How Do the Sites Use Cookies and Other Tracking Technologies?

Like many websites, we use “cookies”, which are small text files that are stored on your computer or equipment when you visit certain online pages that record your preferences and actions. We use cookies to track use of our Sites and online services. We may also use cookies to monitor traffic, improve the Sites and make it easier and/or relevant for your use. Most web browsers automatically accept cookies, but if you prefer, you can usually modify your browser setting to disable or reject cookies. If you delete your cookies or if you set your web browser to decline cookies, some features of the Sites may not work or may not work as designed.

We may also use web beacons and web storage technologies. A web beacon (also known as an “action tag”, “tracer tag”, or “single-pixel gif”) is an invisible graphic on a web page that is programmed to collect information about your use of a given website. Web Storage is a feature in some browsers that permits websites to store data within your browser rather within a cookie. We do not share or provide personally identifiable information we may collect in web beacons or store in web storage, such as names, e-mail addresses and phone numbers, to unaffiliated third parties without your express permission.

We may partner with third party advertising companies to better provide advertisements about goods and services that may be of interest to you. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Sites. They may collect information about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based advertising or other targeted content. These advertising partners do not have access to or use your name, address, e-mail address, telephone number or other personally identifiable information from us, without your consent. They may, however, use persistent identifiers to anonymously track your Internet usage across other websites in their networks beyond these Sites. While we restrict their further use of such information, such third parties may, with sufficient data from other sources, be able to personally identify you, unknown to us.

Third-party ad serving companies and other unaffiliated advertisers may also display advertisements on our site. As part of their service, they may place a separate cookie on your computer or utilize other data collection and tracking technologies, to collect information such as your IP address, browser type, the server your computer is logged onto, the area code and zip code associated with your server, and whether you responded to a particular advertisement. We do not control these third parties’ tracking technologies, how they may be used, or the information they may collect and we are not responsible for the privacy policies or the content of those third parties. Please visit the sites of those businesses to review their privacy policies.

Your browser or device may include “Do Not Track” functionality. Because a “Do Not Track” compliance protocol has not yet been finalized, NTU’s information collection and disclosure practices, and the choices that we provide to customers, will continue to operate as described in this Privacy Policy, whether or not a Do Not Track signal is received.

How Do We Use Your Information?

We use the information we learn from you to help us personalize and continually improve your experience on the Sites, including to:

- Provide you with the content, products and services you request - Post your user generated content to our Sites as you request - Communicate with you about your account or transactions with us and send you information about features and enhancements on or to our Sites - Communicate with you about changes to our policies - Communicate with you about your comment to a story or topic - Personalize content and experiences on our Sites, including providing you recommendations based on your preferences - Send you newsletters, offers and promotions for our products and services, third party products and services, or special events by e-mail, text, or other mediums - Provide you with advertising, including advertising based on your activity on our Sites or activity on third party sites and applications - Administer our loyalty or incentive programs - Administer contests, sweepstakes, promotions, and surveys - Optimize or improve our products, services and operations - Detect, investigate, and prevent activities that may violate our policies or be illegal - Perform statistical, demographic, and marketing analysis of users of the Sites and their purchasing patterns

We may use the information from one portion of the Sites on other portions of Sites in our network of Sites, all of which are owned and operated by NTU, and we may combine information gathered from multiple portions of the Sites into a single user record.

Who Can See Your Information?

We will not disclose your personally identifiable information collected to any organizations not part of NTU or its subsidiaries or related entities, except as described in this Privacy Policy.

Third-Party Agents

We have third-party agents, subsidiaries, affiliates and partners that perform functions on our behalf, including, but not limited to, hosting, content syndication, content management tools, social media integration, marketing, analytics, billing and customer service. These entities may have access to personally identifiable information if needed to perform their functions. If such access is required, the third parties will be obligated to maintain the confidentiality and security of that personally identifiable information. They are restricted from using, selling, distributing or altering this data in any way other than to provide the requested services to the Sites.

Business Partners and Other Third Parties

From time to time we allow companies whose products or services we feel may interest our users to advertise to those users, using the names and addresses provided to us during the process of subscribing to a NTU publication or service. We may share our subscribers’ names and addresses directly with these companies or use a third party to administer the process on our behalf. Many of our subscribers find this a valuable and time-saving service. If you do not want your name and address to be shared for these purposes, you can opt-out of such sharing by e-mailing us at support(at)newthreeuniversity(dot)com, or calling or writing us at the contact information provided.

Assignment

In the event of a corporate change in control resulting from, for example, a sale to, or merger with, another entity, or in the event of a sale of assets or a bankruptcy, NTU may transfer your personally identifiable information to the new party in control or the party acquiring assets. Under such circumstances we would, to the extent possible, require the acquiring party to follow the practices described in this Privacy Policy, as it may be amended from time to time. Nevertheless, we cannot promise that an acquiring company or the merged company will have the same privacy practices or treat your information the same as described in this Privacy Policy.

Law Enforcement, Legal Process, and Emergency Situations

In some cases, we may use or disclose your personally identifiable information to a third party if we are required to do so by law or if we in good faith believe that such action is necessary to comply with the law or legal process such as the Electronic Communications Privacy Act or the Child Online Privacy Act; to protect and defend our rights or to prevent misuse of our Sites; or to protect the personal safety of our employees, agents, partners, the users of the Sites, or the public.

Use of Non-Personally Identifiable Information

We may disclose or share individual, non-personally identifiable information and aggregate information in any manner other than that described herein that we deem appropriate or necessary. Among other things, we will disclose non-personally identifiable information to third parties to help us determine how people use parts of the Sites and who our users are so we can improve our Sites. We will also disclose non-personally identifiable information to our partners and other third parties about how our users collectively use the Sites.

What Are Your Choices?

We believe you should have choices about the collection, use and sharing of your information. Although you cannot opt-out of all data collection when you visit our Sites, you can limit the collection, use and sharing of your information.

Collection of personally identifiable information

All personally identifiable information is provided on a voluntary basis. If you do not want NTU to collect such information, you should not submit it to the Sites. However, doing so will restrict your ability to access some content and use some of the functionality of the Sites.

Sharing of personally identifiable information

You may opt-out of having your personally identifiable information shared with business partners and third parties for marketing and advertising purposes by e-mailing us at support(at)newthreeuniversity(dot)com, or contacting us at the phone numbers or postal address provided below.

Online, Interest Based Advertising

You may be able to opt-out of the use of your information for online, interest based advertising from participating advertising partners and unaffiliated third parties through the Network Advertising Initiative’s opt-out program by clicking http://www.networkadvertising.org/managing/opt_out.asp.

Emails and Newsletters

You may always opt-out of receiving future e-mail marketing messages and newsletters from NTU by following the instructions contained within the emails and newsletters, or by e-mailing, calling or writing us at the addresses below.

Governing Law & Notice to Non-U.S. Users

These Sites are published in the United States. We attempt to protect the personally identifiable information of all users of our Sites and we attempt to comply with local data protection and consumer rights laws to the extent they may apply to NTU’s services, but our family of Sites are located and targeted to United States citizens and our policies are directed at compliance with those laws. If you are uncertain whether this Privacy Policy conflicts with the applicable local privacy laws where you are located, you should not submit your personally identifiable information to NTU.

If you are located outside the United States of America, you should be aware that information about you will be transferred to the United States of America. If you are located in a country outside the United States of America and voluntarily submit personally identifiable information to us, you thereby consent to the general use of such information as provided in this Privacy Policy and to the transfer of that information to, and/or storage of that information in, the United States of America.

Other Important Information

How Your Information Is Secured

We take reasonable security measures to protect your information, including the use of physical, technical and administrative controls. Please understand, however, that while we try our best to safeguard your personally identifiable information once we receive it, no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. You need to help protect the privacy of your own information. You must take precautions to protect the security of any personally identifiable information that you may transmit over any home networks, wireless routers, wireless (WiFi) networks or similar devices by using encryption and other techniques to prevent unauthorized persons from intercepting or receiving any of your personally identifiable information. You are responsible for the security of your information when using unencrypted, open access or otherwise unsecured networks.

The time period for which we keep information varies according to the purpose for which it is used. In some cases, there are legal requirements to keep data for a minimum period. Unless there is a specific legal requirement for us to keep the information, we will retain it for no longer than is necessary for the purposes for which the data was collected or for which it is to be further processed.

In the unlikely event that we believe that the security of your information in our possession or control may have been compromised, we may seek to notify you. If notification is appropriate, we may notify you via your computer, mobile or other device.

Responsible Disclosure of Security Vulnerabilities

No technology is perfect, and NTU believes that working with skilled security researchers across the globe is crucial in identifying weaknesses in any technology. If you believe you've found a security issue in our product or service, we encourage you to notify us. We welcome working with you to resolve the issue promptly.

Disclosure Policy

Let us know as soon as possible upon discovery of a potential security issue, and we'll make every effort to quickly resolve the issue. Provide us a reasonable amount of time to resolve the issue before any disclosure to the public or a third-party. Make a good faith effort to avoid privacy violations, destruction of data, and interruption or degradation of our service. Only interact with accounts you own or with explicit permission of the account holder.

Exclusions

While researching, refrain from: Denial of service; Spamming; Social engineering (including phishing) of NTU staff or contractors; Any physical attempts against NTU property or data centers. While we currently do not have a formal vulnerability reporting system in place at this time, please reach out to support(at)newthreeuniversity(dot)com to report any critical issues you may discover. Thank you for helping keep NTU and our users safe.

Contests, Sweepstakes, Events or Promotions

When we run a contest, sweepstakes, events or promotions relating to our Sites, it will be accompanied by a set of rules. The rules for each contest, sweepstakes, events or promotion will specify how the information gathered from you for entry will be used and disclosed if it is different than as described in this Privacy Policy. In conjunction with your entry in such contest, sweepstakes, events or promotion, personally identifiable information will be collected only if you voluntarily submit it.

Children’s Information

The Sites are not intended for children under 13 years of age. NTU does not knowingly collect personal information from children under 13 years of age. If you are under 13 years of age, do not provide personal information to NTU without providing us with consent from your parents. If NTU discovers that a child under the age of 13 has provided NTU with personal information and we do not have parental consent, NTU will immediately delete that child’s information from the Sites. If you believe that NTU has been provided with the personal information of a child under the age of 13 without parental consent, please notify us immediately at support(at)newthreeuniversity(dot)com.

Your California Privacy Rights

California Civil Code Section 1798.83 permits visitors and customers of NTU who are California residents to request and obtain from NTU once a year, free of charge, certain information regarding its disclosure of their personally identifiable information to third parties for their direct marketing purposes during the prior calendar year. In response to your written request, NTU is allowed to, instead, provide you with a cost-free means to opt-out of such sharing, or a “Customer Choice Notice”. NTU has chosen to provide you with a cost-free means to opt-out of such sharing. To make such a request, please send an e-mail to support(at)newthreeuniversity(dot)com specifying that you seek to opt-out of the sharing of your personal information with third parties for marketing purposes. Please allow thirty days for a response. It is important to note that this opt-out does not prohibit disclosures made for non-marketing purposes.

Questions About this Policy; Access to Your Information

If you have an account with NTU, you may review and change your information by logging into your account and editing your account profile. If you have questions about our Privacy Policy, you may contact us at:

You may also use the contact information provided to request access or changes to your personally identifiable information; however, you will not be permitted to examine the personally identifiable information of any other person or entity and may be required to provide us with personally identifiable information to verify your identity prior to accessing any records containing information about you. We may not accommodate a request to change or delete personally identifiable information if we believe doing so would violate any law or legal requirement, or cause the information to be incorrect.